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5 results for “transfer pricing”+ Section 271Cclear

Sorted by relevance

Mumbai32Delhi30Bangalore6Kolkata5Ahmedabad4Visakhapatnam3Jaipur1Pune1SC1Telangana1Varanasi1

Key Topics

Section 194H14Section 2508Section 2018Section 271C6Deduction5TDS4Section 403Section 201(1)2Section 282Penalty

N C SHAW AND CO BEVERAGES PRIVATE LIMITED ,KOLKATA vs. INCOME TAX OFFICER, TDS CIRCLE 2(2), KOLKATA, KOLKATA

In the result, the appeal filed by the assessee is allowed

ITA 1925/KOL/2024[2015-16]Status: DisposedITAT Kolkata27 Dec 2024AY 2015-16

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 194HSection 201Section 201(1)Section 250Section 271CSection 28

transfer of title to the goods for a price paid or promised to be paid. The transferee in such a case is liable to the transferor as a debtor for the price to be paid and not as agent for the proceeds of the sale. The essence of agency to sell is the delivery of the goods to a person

N C SHAW AND CO BEVERAGES PRIVATE LIMITED,KOLKATA vs. ADDL. COMMISSIONER OF INCOME TAX (TDS), RANGE-2, KOLKATA, KOLKATA

2
Natural Justice2

In the result, the appeal filed by the assessee is allowed

ITA 1947/KOL/2024[2015-16]Status: DisposedITAT Kolkata27 Dec 2024AY 2015-16

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 194HSection 201Section 201(1)Section 250Section 271CSection 28

transfer of title to the goods for a price paid or promised to be paid. The transferee in such a case is liable to the transferor as a debtor for the price to be paid and not as agent for the proceeds of the sale. The essence of agency to sell is the delivery of the goods to a person

M/S VODAFONE EAST LTD.(FORMERLY KNOWN AS VODAFONE ESSAR EAST LIMITED),KOLKATA vs. A.D.I.T RANGE - 7,KOL., KOLKATA

In the result, the appeal of the revenue in ITA No

ITA 1864/KOL/2012[2009-10]Status: DisposedITAT Kolkata15 Sept 2015AY 2009-10

Bench: Shri Mahavir Singh & Shri M. Balaganesh

Section 143(3)Section 194ISection 40

pricing formula finally adopted. There is nothing on record to support the Revenue's contention that the wheeling and transmission charges assumes the character of rent. We are in agreement with Mr. Mistri that the expression "rent" must be conceptually understood. The concept of rent under the Income-tax Act does not encompass, in our view, the wheeling and transmission

ACIT, CIR-3(TDS), KOLKATA, KOLKATA vs. VODAFONE MOBILE SERVICES LTD. (FORMERLY KNOWN AS VODAFONE EAST LTD.), KOLKATA

In the result, both the appeals of the revenue are dismissed

ITA 1071/KOL/2016[2012-2013]Status: DisposedITAT Kolkata19 Jan 2018AY 2012-2013

Bench: Sri J. Sudhakar Reddy & Sri S. S. Viswanethra Ravi]

Section 194HSection 201Section 250Section 271C

price. The amount of discount is not recorded in the books of accounts. Therefore we hold the transaction between the assessee and prepaid distributor for recharge coupons is nature of sale & purchase. Thus amount of discount cannot be equated with the commission as envisaged under section 194H of the Act. Similarly we find that the ownership of the recharge coupons

ACIT, CIR-3(TDS), KOLKATA, KOLKATA vs. VODAFONE MOBILE SERVICES LTD. (FORMERLY KNOWN AS VODAFONE SOUTH LTD.), KOLKATA

In the result, both the appeals of the revenue are dismissed

ITA 1072/KOL/2016[2012-2013]Status: DisposedITAT Kolkata19 Jan 2018AY 2012-2013

Bench: Sri J. Sudhakar Reddy & Sri S. S. Viswanethra Ravi]

Section 194HSection 201Section 250Section 271C

price. The amount of discount is not recorded in the books of accounts. Therefore we hold the transaction between the assessee and prepaid distributor for recharge coupons is nature of sale & purchase. Thus amount of discount cannot be equated with the commission as envisaged under section 194H of the Act. Similarly we find that the ownership of the recharge coupons